Mar 24 2026
4th Cir. 25-6012 Per Curiam

BILLY G. ASEMANI v. DIRECTOR, OFFICE OF DETENTION & REMOVAL, DEPARTMENT OF HOMELAND SECURITY, IMMIGRATION & CUSTOMS ENFORCEMENT

The Fourth Circuit vacated and remanded a district court's dismissal of a habeas petition, clarifying that a final order of removal satisfies the 'in custody' requirement of 28 U.S.C. § 2241 even when a noncitizen is physically confined by state authorities. The court held that the restraint on liberty imposed by a final deportation order is sufficient to confer federal habeas jurisdiction.

Mar 24 2026
10th Cir. 2:25-CV-00106-DBB Panel Decision

LYNDA GARDNER; KANDRA AMBOH v. UTE TRIBAL COURT OF THE UINTAH AND OURAY RESERVATION; JEFFREY KURTZ; JEFF S RASMUSSEN

The Tenth Circuit dismissed this appeal as moot because the underlying tribal criminal charges against Kandra Amboh concluded with a not guilty verdict. Consequently, no live controversy remained for the federal court to resolve regarding her detention.

Mar 23 2026
3rd Cir. 25-2712 Panel Decision

OMAR SIERRE FOLK v. WARDEN SCHUYLKILL FCI

The Third Circuit affirmed the denial of a federal prisoner's motion to reopen a final habeas judgment based on the Supreme Court's Loper Bright decision. The court held that a change in administrative law deference principles does not constitute an extraordinary circumstance under Rule 60(b)(6) when the new legal theory is unrelated to the original claim.

Mar 23 2026
11th Cir. 6:23-cv-00486-JSS-DCI Per Curiam

Raymond L. Strong v. Secretary, Department of Corrections

The Eleventh Circuit dismissed Raymond L. Strong's appeal because his notice of appeal was filed after the statutory deadline expired. The court found that Strong failed to meet the requirements for reopening the appeal period under Federal Rule of Appellate Procedure 4(a)(6).

Mar 20 2026
U.S. Sup. Ct. 24-993 Unanimous

Olivier v. City of Brandon

The Supreme Court held that a §1983 plaintiff seeking purely prospective injunctive relief is not barred by Heck v. Humphrey, even if they have a prior conviction for violating the challenged law. The Court reasoned that Heck only precludes claims where a favorable judgment would necessarily imply the invalidity of the conviction for the purpose of release or damages, not challenges to future enforcement.

Mar 19 2026
6th Cir. 22-3544 Published

MARVIN G. JOHNSON v. DAVID BOBBY, Warden

The Sixth Circuit held that a state prisoner's federal habeas petition is not rendered moot by a subsequent resentencing from death to life without parole, as long as the underlying conviction remains intact. The court affirmed the denial of Johnson's petition, rejecting claims of ineffective assistance of counsel regarding the admission of criminal history evidence and the failure to raise a Confrontation Clause challenge.